Below are a sampling of disclosures made in October that warn of potential problems. Please be aware that the excerpts below are just that: excerpts. The complete SEC filings are available for those who would like to review the complete disclosures in greater detail. For related information on the list below, please refer to the […]
Internal Controls
Internal Control Disclosures In October: Changes
Below are a sampling of disclosures made in October that describe changes to the state of their internal control over financial reporting, as required by SOX 302. Please be aware that the excerpts below are just that: excerpts. The complete SEC filings are available for those who would like to review the complete disclosures in […]
Largest Accounting Firms Issue Joint 404 Framework
Last week, nine accounting firmsโincluding eight of the largest in the countryโissued a joint framework for use in implementing Section 404 of The Sarbanes-Oxley Act. This paper, released Oct. 28, outlines a “suggested framework for evaluating manual and automated process/transaction-level exceptions and deficiencies” resulting from the evaluation of a companyโs internal control over financial reporting. […]
Q&A With CCO, VP Of Risk Management At Qwest
This profile is the latest in a series of weekly conversations with executives at U.S. public companies who are currently involved in establishing and developing compliance programs. An index of previous conversations is available here. Delineate your compliance and your risk duties for us. We take an enterprise risk management approach. I have the chief […]
Why Section 404 Could Hold Up Quarterly Filings
When Flowserve Corp. announced last week it would delay the filing of its second and third quarter filings, it came as little surprise to those who follow the $2.4 billion maker of pumps, valves, and flow control equipment. After all, this is the third straight quarter it has postponed its quarterly filing. In the second […]
UK, Irish Companies Get SOX Compliance Assistance
The U.K. Financial Reporting Council is offering some assistance to U.K. and Irish companies registered with the U.S. Securities and Exchange Commission on how to comply with Sarbanes-Oxley requirements regarding internal controls. The good news for those foreign-based companies is that the SEC has said it will accept the framework many of those companies are […]
Companies Migrating From SOX ‘Myopia’ To ERM
Howโs this for an understatement: โThere has developed what seems to be an overemphasis on certain additional or duplicative levels of documentation, with a declining value in terms of how much that additional documentation would add to the effectiveness of internal control.โ Thatโs according to Arnie Hanish, the chief accounting officer of Eli Lilly and […]
Q&A With IKON’s General Counsel & Secretary
This profile is the latest in a series of weekly conversations with executives at U.S. public companies who are currently involved in establishing and developing compliance programs. An index of previous conversations is available here. You are general counsel and corporate secretary, as well as chief compliance officer. How much of your time goes to […]
Electronic Records Retention: Getting It Right
The computer’s common use as an essential business tool, and the tremendous and exponentially increasing storage capacity of computer generated or recorded information has transformed the landscape of information retention and destruction. Now record retention regulations are becoming increasingly important to follow, and follow correctly and consistently. Certain regulations in particular illustrate this need, including […]
Q&A With Kaiser Permanente’s Compliance Officer
This profile is the latest in a series of weekly conversations with executives at U.S. public companies who are currently involved in establishing and developing compliance programs. An index of previous conversations is available here. Weโve never interviewed the compliance officer of a nonprofit before. What do you oversee? Well, Kaiser is a complicated institution. […]


